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Legal Alert: Camping on "The Street": A First Step in the Reform of the...

On January 24, House Ways and Means Committee Chairman Camp (R-MI) released a discussion draft of proposals to reform the taxation of certain financial instruments and products (the Camp Draft). In...

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Have You "Begun Construction"? IRS Issues Guidance for Renewable Energy Tax...

On April 15, 2013, the Internal Revenue Service ( IRS) issued much - anticipated guidance that will help developers of wind, solar, biomass and certain other renewable energy facilities qualify for...

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Legal Alert: IRS Clarifies "Binding Written Contract" Definition in Renewable...

On April 25, 2013, the Internal Revenue Service updated guidance issued on April 15, 2013, that explained how to satisfy the new “begun construction” requirement for the renewable energy section 45...

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Legal Alert: Tax Court Finds Indirect Prohibited Transaction in IRA

In Peek v. Commissioner (May 9, 2013), the U.S. Tax Court ruled that two taxpayers had engaged in an indirect “prohibited transaction” with their individual retirement accounts (IRAs) when they...

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Legal Alert: Not Exactly a Day in the Sun: U.S. Court of Appeals Holds...

In Sun Capital Partners III LP v. New England Teamsters & Trucking Industry Pension Fund, No. 12-2312, 2013 WL 3814984 (1st Cir. July 24, 2013), the U.S. Court of Appeals for the First Circuit...

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DQ’d: New Inversion Regulations Expand the Reach of the Public Offering Rule...

On January 17, Treasury and the IRS published new temporary and proposed regulations under Section 7874 of the Internal Revenue Code that expand the reach of the so-called “public offering rule” of...

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Camp Goes All-In with Comprehensive Tax Plan: Highlights, Tax Reform Status...

On February 26, Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee, released his much-awaited comprehensive tax reform plan (the “Camp Proposal”). That proposal seeks to...

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Legal Alert: Energy Tax Reform: Current Updates And What It Means For...

Energy tax reform has been the subject of three recent, and very significant, administrative and legislative proposals: - The President’s 2015 budget, released on March 4, 2014; - The comprehensive tax...

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Virtual Reality: IRS Provides Guidance on the Treatment of Bitcoin and Other...

On March 25, 2014, the Internal Revenue Service (IRS) issued Notice 2014-21 (the Notice), which provides guidance regarding the tax treatment of Bitcoins and other virtual currency through a series of...

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Clock Is Ticking…Relief for Late Filed GRAs Expected to Expire Soon

Time may be running out for taxpayers to correct technically deficient gain recognition agreements (GRAs) under the relief procedure contained in the Directive on Examination Action With Respect to...

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Are You Really Sure That Construction Began? IRS Issues Third Notice...

On August 8, 2014, the Internal Revenue Service (“IRS”) issued Notice 2014-46, which provides further guidance intended to assist developers and purchasers of renewable energy facilities evaluate...

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